Privacy Policy
This Privacy Policy will explain how our Company uses the personal data we collect from you
when you use our website.
At ecoterra we highly prioritize protecting your personal information and being transparent about
what we do with it. We are committed to using your personal information following all
applicable laws concerning the protection of personal information and ensuring that you
understand your data rights and freedoms.
ecoterra will be considered as the "controllers" of your data. We determine which personal data
we need to process and for what purpose and are responsible for the safe storage and handling of
this data.
First, we need to define, and it is important for you to understand, the expression: "Personal
Data" (PD). It generically represents any kind of information about a physical person, whose
particularities can lead, directly or indirectly, to its identification. Here you have, by way of
example, but not limited to: name and surname, geographical address, any identification number,political orientation, sexual orientation, email address, any location information and any other
online identifier such as the device used to access the Internet, IP address, or cookie information.
With regards of your agreement on collection and use of personal data, we have taken all thenecessary technical measures to provide you with this detailed agreement, so you can have acrisp clear experience, from the first to the last interaction with our website or our services.
Visitors and Users agree and accept that the use of our website is not possible without any
indication of personal data.
In your relationship with us through the website, controller, for the purposes of the General Data
Protection Regulation (GDPR), other data protection laws applicable in Member states of theEuropean Union and other provisions related to data protection, is: Earthup S.R.L., having its
headquarters at 5 Potcoavei Str., Jud. Ilfov, Loc. Voluntari, J23/6570/2021, CUI 45107385.
This Policy does not apply to other companies’ websites to which we may link to or may link tous. You should carefully review the privacy policies of those sites in order to determine how theytreat your personal information.
If you do not agree to this Privacy Policy, please exit, and do not access or use our website.

Definitions
Our data protection policy should be legible and understandable for the general public, as well as
for our Users and business partners. To ensure this, we would like to first explain theterminology used. In this data protection declaration, we use, inter alia, the following terms:● Data Subject or Data Principal - is any identified or identifiable natural person, whose
personal data is collected and processed by us.
● Processing - is any operation which is performed on personal data, such as collection,
recording, Company, structuring, storage, etc.
● Restriction of processing - is the marking of stored personal data with the aim oflimiting their processing in the future.
● Profiling - means any form of automated processing of personal data consisting of theuse of personal data to evaluate certain personal aspects relating to a natural person.
● Data Controller or Data Fiduciary - is the natural or legal person, public authority,
agency or other body, which determines the purposes and means of the processing of
personal data;● Processor - is a natural or legal person, public authority, agency or other body which
processes personal data on behalf of the controller.
● Recipient - is a natural or legal person, public authority, agency or another body, towhich the personal data are disclosed. The processing of those data by those publicauthorities shall be in compliance with the applicable data protection rules according to
the purposes of the processing.
● Third-party - is a natural or legal person, public authority, agency or body other than theones above, who, under the direct authority of the controller or processor, are authorized
to process personal data.
● Consent - is any freely given, specific, informed and unambiguous indication of data
subject’s acceptance to the processing of their personal data.
Compliance
The processing of personal data will be in line with these main international legislations:● General Data Protection Regulation (GDPR), applicable in Europe;● California Consumer Privacy Act (2018) and Privacy Act U.S.C. 552a (Privacy Act ofUSA);
We are able to provide our services worldwide. For the purpose of avoiding any complianceconflict with any terminology used by any particular legislation, in this document: “Users” arethe “data subjects” or the “data principals” and ecoterra is the “data controller” or “datafiduciary”
Our privacy notice tells you what personal data (PD) and non-personal data (NPD) we may
collect from you, how we collect it, how we protect it, how we may share it, how you can accessand change it, and how you can limit our sharing of it. Our privacy notice also explains certain
legal rights that you have with respect to your personal data. Any capitalized terms not defined
herein will have the same meaning as where they are defined elsewhere on our website.
Automated individual decision-making and profiling
You will have the right not to be subject to a decision based solely on automated processing,including profiling, which produces legal effects concerning you or similarly significantly affectsyou.
Filing a complaint with authorities
You have the right to file a complaint with supervisory authorities if your information has notbeen processed in compliance with any applicable data protection law. If the supervisory
authorities fail to address your complaint properly, you may have the right to a judicial remedy.
Use Cases
Please take a moment to understand which use case(s) set out in this Privacy Policy apply to you:
● Website Visitor
You are a “Website Visitor” by definition when you visit our website and any other eventual
subdomains associated with our principal domain. As a website visitor, we use your navigation
statistical information for our own purposes, primarily for improving the use of our website andto provide you with more relevant content.
● User
You become a “User” if you avail any of the services provided on our website/platform. If you
are a User, our primary purpose of using your personal data is for providing the services to you.
We retain your personal information for a limited time and for limited purposes, such as to makeit easier for you to re-join our service in the future or to wish you offers for services that we think
you may be interested in.
What data do we collect?

We are currently under no obligation whatsoever to collect any specific data, but as thelegislative landscape will evolve and develop, we may have to collect, in the future, further
information from you, under the KYC procedure.
So, upon availing our services, we may ask for your full name and a valid e-mail address, which
will be included in our mailing list, for future maintenance, updates, and eventual marketingpromotions. In addition, we will ask you to provide us with secure payment data, which will be
used for processing the order. This particular set of data will be legally processed by our payment
processor, and will not be stored by us.
We may process data about your use of our website and services, or the User’s website ("usagedata"). The usage data may include your IP address, geographical location, browser type, andversion, operating system, referral source, length of visit, page views and website navigation
paths, as well as information about the timing, frequency and pattern of your service use. The
source of the usage data is our analytics tracking system. This usage data may be processed forthe purposes of analyzing the use of the website and services.
We may process your personal data that are provided in the course of the use of our services("service data"). The service data may be processed for the purposes of providing our services,
ensuring the security of our website and services, maintaining back-ups of our databases andcommunicating with you.
We may process information contained in any inquiry you submit to us regarding services and/or
services ("inquiry data"). The inquiry data may be processed for the purposes of providing ourservices, ensuring the security of our website and services, maintaining back-ups of ourdatabases and communicating with you.
We may process information relating to our User relationships, including User contact
information ("User relationship data"). The User relationship data may include your name, youremployer, your job title or role, all your contact details, and information contained incommunications between us and you or your employer. The User relationship data may beprocessed for the purposes of providing our services, ensuring the security of our website andservices, maintaining back-ups of our databases and communicating with you.
We may process information relating to transactions, including purchases of services, that you
enter into with us and/or through our services ("transaction data"). The transaction data may
include your contact details and the transaction details. The transaction data may be processed
for the purposes of providing our services, ensuring the security of our website and services,maintaining back-ups of our databases and communicating with you.

We may process information contained in or relating to any communication that you send to us("correspondence data"). The correspondence data may include the communication content andmetadata associated with the communication. Our website will generate the metadata associatedwith communications made using the website contact forms. The correspondence data may beprocessed for the purposes of providing our services, ensuring the security of our website andservices, maintaining back-ups of our databases and communicating with you.
“Automatically Collected" Information: The website collects a series of general data andinformation when a data subject or automated system calls up the website. This general data andinformation are stored in the server log files, and it is collected regardless of your quality:
Website Visitor or User.
Collected may be:•
the ISP,•
the operating system used by the accessing system•
the website from which an accessing system reaches our website (so-called referrers)•
the sub-website•
the date and time of access to the website•
an Internet Protocol address (IP address)•
screen Resolution•
locale Preferences•
web page visited before you came to our website•
information you search for on our website•
date and time stamps associated with transactions•
system configuration information and other interactions with the website.
•social networking information (if we are provided with access to your account on social
network connection services);•any other similar data and information that may be used in the event of attacks on our
information technology systems.
When using these general data and information, we do not draw any conclusions about the data
subject. Rather, this information is needed to:•deliver the content of our website correctly;•
optimize the content of our website as well as its advertisement;•
ensure the long-term viability of our information technology systems and website
technology;•
provide law enforcement authorities with the information necessary for criminal
prosecution in case of a cyber-attack;In addition to the specific purposes for which we may process your personal data set out in thisSection, we may also process any of your personal data where such processing is necessary forcompliance with a legal obligation to which we are subject, or in order to protect your vitalinterests or the vital interests of another natural person.
Please do not supply any other person's personal data to us, unless we prompt you to do so.
Obviously, the access to our website for website visitors is free; however, we inform you that for
the use of the website via mobile device the charges and the standard tariffs provided in theservice contract that you have stipulated with them will still be applied by the telephone
operators.
How do we collect your data?
You directly provide ecoterra with most of the data collected. We collect data and process datawhen you avail our products and services.
What is the purpose of collection?
Our commercial purpose, by reference to the subject matter of our business, is provision of
cryptocurrency services. Reports in the financial domain and other complementary services, andthe new rules of personal data protection (GDPR, CCPA, etc.) are part of this context.
Complementary purposes
To improve our services.
We always want to offer you the best online experience and for this we can collect and use
certain information about your behavior and preferences when using the website and platform, or
we can conduct market research directly or through partners.
To improve your marketing activity
We may want to keep you informed about the best offers for the services you may be interested
in. In this sense, we may send you any type of message (such as: email / SMS / phone / mobile
push / web push / etc.) containing general and thematic information about products or services,
information on offers or promotions, as well as other commercial communications.
To defend our legitimate interests

There may be situations in which we use or transmit information to protect our rights and ourcommercial activity. These situations may include:measures to protect the website and platform Visitors and Users against cyber-attacks;
measures to prevent and detect fraud attempts;
transmission of information to the competent public authorities;
other risk management measures.
We therefore commit ourselves:to protect the privacy of your data, which is a top priority for our company’s
management;
to use this data for the sole purpose of providing you with a personalized experienceon our website as well as on the online platforms that we promote our products andservices (Facebook and Google, etc.).
How do we store your data?
ecoterra securely stores your data at a third-party dedicated server located in the European
Union. We do not use the information you provide to make any automated decisions that might
affect you.
Our Legal Basis for Collecting and Processing Personal Data
Our legal basis for collecting and processing your personal data when you avail our services isbased on the necessity for the performance of a contract or to take steps to enter into a contract.
What Happens If You Don’t Give Us Your Personal Data
If you do not provide us with enough Personal Data, we may not be able to provide you with ourservices. However, you can access and use some parts of our website (not our platform) without
giving us your Personal Data.
What are your data protection rights?
ecoterra would like to make sure you are fully aware of all of your data protection rights. Every
user is entitled to the following:
The right to be informed – You have the right to be informed about the personal data we collectfrom you, and how we process it.
The right to access – You have the right to request ecoterra for copies of your personal data. We
may charge you a small fee for this service.

The right to rectification – You have the right to request that ecoterra correct any information
you believe is inaccurate. You also have the right to request ecoterra to complete the information
you believe is incomplete.
The right to erasure – You have the right to request that ecoterra erase your personal data,
under certain conditions.
The right to restrict processing – You have the right to request that ecoterra restrict theprocessing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to ecoterra’s processing of yourpersonal data, under certain conditions.
The right to data portability – You have the right to request that ecoterra transfer the data that
we have collected to another Company, or directly to you, under certain conditions.
Cookies Policy
Cookies are text files placed on your computer to collect standard Internet log information andvisitor behavior information. When you visit our websites, we will collect information from you
automatically through cookies or similar technology
For further information, visit allaboutcookies.org.
How do we use cookies?
ecoterra uses cookies in a range of ways to improve your experience on our website, including:● Keeping you signed in● Understanding how you use our website● To authenticate you
What types of cookies do we use?
There are several different types of cookies, however, our website uses:● Functionality – ecoterra uses these cookies so that we recognize you on our website andremember your previously selected preferences. These could include what language you
prefer and the location you are in. A mix of first-party and third-party cookies are used.
ecoterra uses these cookies to collect information about your visit to our website, thecontent you viewed, the links you followed, and information about your browser, device,and your IP address.
● Strictly Necessary cookies– let you move around the website and use essential features
like secure areas. Without these cookies, we cannot provide the requested services.We
use these strictly necessary cookies to:oo

Identify you as being logged in to the website and to authenticate you
Make sure you connect to the right service on the website when we make anychanges to the way it works
o For security purposes● 'Performance' cookies – collect information about how you use the website, e.g. which
pages you visit, and if you experience any errors. These cookies do not collect any
information that could identify you and are only used to help us improve how the website
works. We use performance cookies to:•Help us improve the website by measuring any errors that occur•
Test different designs for the website
How to manage cookies
You can set your browser not to accept cookies, allaboutcookies.org tells you how to remove
cookies from your browser. However, in a few cases, some of our website features may not
function as a result.
Privacy policies of other websites
The ecoterra website/platform contains links to other websites. Our privacy policy applies only
to our website, so if you click on a link to another website, you should read their privacy policy.
Changes to our privacy policy
ecoterra keeps its privacy policy under regular review and places any updates on this web page.
This privacy policy was last updated on 01 November 2021.
How to contact us
If you have any questions about ecoterra’s privacy policy, the data we hold on you, or you would
like to exercise one of your data protection rights, please do not hesitate to contact us by email
at: legal@ecoterra.io
Sharing Information with Affiliates and Other Third Parties
We do not sell or rent your PD to third-parties for marketing purposes. You understand, and weundertake, that we will provide your PD through our platform strictly to the corporate
stakeholders that are using our platform. However, for data aggregation purposes we may use
your non PD, which might be sold to other parties at our discretion. Any such data aggregation

would not contain any of your PD. We may provide your PD to third-party service providers wehire to provide services to us. These third-party service providers may include but are not limited
to: payment processors, web analytics companies, advertising networks, call centers, data
management services, help desk providers, accountants, law firms, auditors, shopping cart andemail service providers, and shipping companies.
Retaining and Destroying Your PD
We only retain the personal information collected from a User for as long as the User’s accountis active on our platform, or otherwise for a limited period of time as long as we need it to fulfill
the purposes for which we have initially collected it, unless otherwise required by law.
In some cases, it is not possible for us to specify in advance the periods for which your personal
data will be retained. In such cases, we will determine the period of retention based on the 2-year
criteria, after your relationship with us ends.
We may retain your personal data where such retention is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital interests or the vital interestsof another natural person.
California Privacy Rights
In addition to the rights provided for above, if you are a California or US resident, you have theright to request information from us regarding whether we share certain categories of yourpersonal information with third parties for the third parties' direct marketing purposes. To theextent we share your personal information in this way, you may receive the following
information:(a) the categories of information we disclosed to third parties for the third parties' direct
marketing purposes during the preceding calendar year; and(b) the names and addresses of third parties that received such information, or if the nature of
their business cannot be determined from the name, then examples of the products or services
marketed.
Effective January 1, 2020, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”),
California residents have certain rights in relation to their personal information, subject to limited
exceptions. Any terms defined in the CCPA have the same meaning when used in this California
Privacy Rights section.
● For personal information collected by us during the preceding 12 months that is
not otherwise subject to an exception, California residents have the right to accessand delete their personal information. ecoterra will not discriminate against thosewho exercise their rights. Specifically, if you exercise your rights, we will notdeny you services, charge you different prices for services or provide you adifferent level or quality of services.
● To the extent we sell your personal information to third parties, you also have theright to request that we disclose to you: (i) the categories of your personal
information that we sold, and (ii) the categories of third parties to whom yourpersonal information was sold. You have the right to direct us not to sell yourpersonal information. ecoterra does not sell your personal information in its
ordinary course of business and will never sell your personal information to third
parties without your explicit consent.
Should ecoterra engage in any of the activities listed in this section, your ability to exercise theserights will be made available to you in your account settings. You can exercise your rights bycontacting us via email so that we may consider your request.
If you are a US resident, you may designate an authorized agent to make a request to access or arequest to delete on your behalf. We will respond to your authorized agent's request if theysubmit proof that they are registered with the California Secretary of State to be able to act on
your behalf, or submit evidence you have provided them with power of attorney pursuant to
California Probate Code section 4000 to 4465. We may deny requests from authorized agents
who do not submit proof that they have been authorized by you to act on their behalf, or are
unable to verify their identity.
Transferring PD From the European Economic Area
PD that we collect from you may be stored, processed, and transferred between any of thecountries in which we operate. The European Union and the UK has not found the United Statesand some other countries to have an adequate level of protection of PD under Article 45 of the
GDPR. Our company relies on derogations for specific situations as defined in Article 49 of the
GDPR. For European Union customers and users, with your consent, your PD may be transferredoutside the European Union to the United States and or other countries. We will use your PD toprovide the services, and/or information you request from us to perform a contract with you or tosatisfy a legitimate interest of our company in a manner that does not outweigh your freedoms
and rights. Wherever we transfer, process or store your PD, we will take reasonable steps toprotect it. We will use the information we collect from you in accordance with our privacy
notice. By using our website, services, or products, you agree to the transfers of your PD
described within this section.

Changes to Our Privacy Policy
We reserve the right to change this privacy notice at any time. If our company decides to change
this privacy notice, we will post those changes on our website so that our users and customers arealways aware of what information we collect, use, and disclose. If at any time we decide todisclose or use your PD in a method different from that specified at the time it was collected, we
will provide advance notice by email (sent to the email address on file in your account).
Otherwise we will use and disclose our users’ and customers’ PD in agreement with the privacy
notice in effect when the information was collected. In all cases, your continued use of our
website, services, and products after any change to this privacy notice will constitute youracceptance of such change.